Modern (anti) Slavery Policy for Yesway Limited (January 2024 revision)

  1. Introduction As an employer based in the United Kingdom, Yesway Limited are committed to combating modern slavery and human trafficking in all its forms. This policy outlines our commitment to preventing modern slavery within our operations and supply chains and sets out the actions we will take to achieve this goal.
  2. Policy Statement: We condemn all forms of modern slavery, including forced labour, human trafficking, servitude, and forced or compulsory labour. We recognize that modern slavery is a global issue that requires concerted efforts from businesses, governments, and civil society to address effectively.
  3. Responsibilities All employees, contractors, and suppliers are expected to familiarise themselves with this policy and adhere to its principles. Key responsibilities include:
    • Management: Ensuring that effective systems and controls are in place to prevent modern slavery within our operations and supply chains.
    • Employees: Reporting any concerns related to modern slavery to the designated point of contact.
    • Suppliers: Ensuring that our suppliers adhere to the same standards and principles outlined in this policy.
  1. Risk Assessment We will conduct regular risk assessments to identify and assess the risk of modern slavery within our operations and supply chains. This will include evaluating the countries, industries, and suppliers most at risk and taking appropriate action to mitigate these risks.
  2. Due Diligence We will undertake due diligence processes to assess and monitor our suppliers’ compliance with our standards on modern slavery. This may include:
    • Assessing suppliers’ policies and practices related to modern slavery.
    • Conducting site visits and audits to evaluate working conditions.
    • Providing training and guidance to suppliers on modern slavery awareness and prevention.
  1. Training and Awareness: We will provide training and awareness programs to all employees to ensure they understand the risks of modern slavery and their role in preventing it. This will include:
    • Training on identifying signs of modern slavery.
    • Guidance on reporting mechanisms for concerns related to modern slavery.
    • Regular updates and refresher courses to ensure ongoing awareness.
  1. Reporting and Whistleblowing: We encourage all employees to report any concerns or suspicions of modern slavery through our whistleblowing procedures. Reports will be taken seriously and investigated promptly and confidentially. We will not tolerate any retaliation against whistleblowers who raise genuine concerns in good faith.
  2. Continuous Improvement We are committed to continuously improving our efforts to tackle modern slavery. This includes:
    • Reviewing and updating this policy regularly to reflect changes in legislation, best practices, and emerging risks.
    • Engaging with stakeholders, including employees, suppliers, and civil society organisations, to gather feedback and input on our approach.
  1. Compliance and Enforcement Compliance with this policy is mandatory for all employees, contractors, and suppliers. Failure to comply may result in disciplinary action, termination of contracts, or legal consequences, depending on the severity of the violation.
  2. Communication This policy will be communicated to all employees and made available to the public on our website. We will also communicate our commitment to tackling modern slavery to our stakeholders through various channels.
  3. Conclusion By implementing this policy, we (Yesway Limited) reaffirm our commitment to upholding human rights and ethical labour practices. We recognise that eradicating modern slavery requires collective action and are committed to playing our part in this important endeavour.

This policy will be reviewed annually to ensure its effectiveness and relevance.

Signed: Craig Miles, Director, on behalf of Yesway Limited.

Additional Notes:

  1. Mitigation:
    • Risk Assessment: The policy includes a commitment to conducting regular risk assessments to identify and assess the risk of modern slavery within the organisation’s operations and supply chains.
    • Due Diligence: It outlines due diligence processes to assess and monitor suppliers’ compliance with modern slavery standards, thus mitigating the risk of exploitation within the supply chain.
  1. System:
    • Management Responsibilities: The policy assigns responsibility to management for ensuring effective systems and controls are in place to prevent modern slavery, demonstrating a systematic approach to addressing the issue.
    • Reporting and Whistleblowing: The policy establishes reporting mechanisms for employees to raise concerns related to modern slavery, creating a systematic process for addressing issues as they arise.
  1. Action:
    • Training and Awareness: The policy includes provisions for training and awareness programs for employees to identify signs of modern slavery and understand their role in prevention, demonstrating proactive action.
    • Continuous Improvement: It commits to continuously improving efforts to tackle modern slavery through regular policy reviews, stakeholder engagement, and updating procedures, emphasising ongoing action and improvement.
  1. Transparency:
    • Communication: The policy commits to communicating the organisation’s commitment to tackling modern slavery to stakeholders through various channels, including making the policy publicly available on the website, promoting transparency.
    • Compliance and Enforcement: By stating consequences for non-compliance with the policy, such as disciplinary action or termination of contracts, the policy promotes transparency in enforcing ethical standards throughout the organisation and its supply chains.

By addressing requirements under the MSAT criteria, our Modern Slavery Policy demonstrates a comprehensive approach to tackling modern slavery within the organisation’s operations and supply chains, emphasising mitigation, systematic action, and transparency in combating this issue.